The opinion of the court was delivered by: Judge: Honorable William B. Shubb
JOHN R. MANNING (SBN 220874) ATTORNEY AT LAW 1111 H Street, # 204 Sacramento, CA. 95814 (916) 444-3994 Fax (916) 447-0931 Attorney for Defendant MICHAEL LEONARD LOVATO
Date: November 7, 2011 Time: 9:30 a.m.
STIPULATION AND ) [PROPOSED ORDER] CONTINUING STATUS CONFERENCE
IT IS HEREBY stipulated between the United States of America through its undersigned counsel, Jill M. Thomas, Assistant United States Attorney, together with counsel for defendant Michael Leonard Lovato, John R. Manning, Esq., counsel for defendant Michael Valentino Lovato, Kelly Babineau, Esq., counsel for defendant Jonathan Gonzalez, Danny D. Brace, Jr., Esq., counsel for defendant Andre Kovacs, James P. Chandler, Esq., counsel for defendant Tony Rosales, Dan F. Koukol, Esq., counsel for defendant Adrianna Cano, Mark J. Reichel, Esq., and counsel for defendant Derick Noble, Timothy E. Warriner, Esq., that the status conference presently set for September 26, 2011 be continued to November 7, 2011, at 9:30 a.m., thus vacating the presently set status conference for all defendants with the exception of defendant Amador Eli Rosales, who wishes to remain on calendar to enter a change of plea.
Defense counsel requires additional time to review the voluminous discovery and perform investigation. Therefore, counsel for the parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the defendants and the public in a speedy trial. 18 U.S.C. 3161(h)(7)(A) (continuity of counsel/ reasonable time for effective preparation) and Local Code T4, and agree to exclude time from the date of the filing of the order until the date of the status conference, November 7, 2011.
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA, Plaintiff, v. AMADOR ELI ROSALES, et al., Defendants.
ORDER TO CONTINUE STATUS CONFERNCE
GOOD CAUSE APPEARING, it is hereby ordered that the September 26, 2011 status conference be continued to November 7, 2011 at 9:30 a.m. I find that the ends of justice warrant an exclusion of time and that the defendant's need for continuity of counsel and reasonable time for effective preparation exceeds the public interest in a trial within 70 days. THEREFORE IT IS FURTHER ORDERED that time be excluded pursuant to 18 U.S.C. 3161(h)(7)(A) and Local Code T4 from the date of this order to November 7, 2011.
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